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Jackson v. County of McLean, 953 F.2d 1070, 1071 (7th Cir. 1992): Indigent civil litigants have no constitutional or statutory right to be represented by counsel in federal court. The district court, however, may in its discretion request counsel to represent indigent civil litigants in certain circumstances under 28 U.S.C. 1915(d) . In determining whether to appoint counsel, the district court should consider: (1) the merits of the indigent's claim for relief; (2) the ability of the indigent plaintiff to investigate crucial facts unaided by counsel; (3) whether the nature of the evidence indicates that the truth will more likely be exposed where both sides are represented by counsel; (4) the capability of the indigent to present the case; and (5) the complexity of the legal issues raised by the complaint.